“Be very skeptical of promises that you’ll make a lot of money by working from home,” said Andrew Smith, Director of the FTC’s Bureau of Consumer Protection. “In this case and many others, we see companies that are just out to take your money, not help you make it.”

According to the complaint, starting in 2014 and continuing through 2017, Gregory W. Anderson, Garrett P. Robins, and five companies they controlled, charged consumers an up-front fee, typically $97, to join a program that purportedly would allow them to make significant income from home by posting advertising links onto websites. Consumers who paid this fee soon realized the program did not actually supply any advertising links or pay them to perform any work.

As alleged, consumers were first lured into this scam by ads appearing in spam emails blasted nationwide by affiliate marketing networks hired by the defendants to promote their program. These spam emails contained links that, when clicked, routed consumers to the defendants’ so-called “presale” websites, which falsely mimicked honest reviews by independent news reporters lauding the wonders of the defendants’ moneymaking opportunity. These bogus review sites actually were maintained by the defendants themselves. The review sites also contained links that, when clicked, sent consumers to the defendants’ sales websites, where consumers could pay to enroll in the defendants’ program. These sales websites promised significant income with little effort, and showed testimonials including a prominent story about a single mother who had lost her job and then became a millionaire. These testimonials were also false. The people featured were not even real customers.

The defendants marketed their bogus program under various names, including Online Cash Commission, Excel Cash Flow, and, most recently, Cash From Home. The complaint alleges that the defendants pocketed several million dollars from consumers who paid to join their bogus program, and took in several million more by tricking their customers into calling certain telemarketing sales floors that sold them one-on-one business coaching packages costing thousands of dollars.

The complaint charges the defendants with violations of Section 5 of the FTC Act, the Business Opportunity Rule, and the Telemarketing Sales Rule.

The settlement order bans Anderson and Robins – along with their companies Fat Giraffe Marketing Group LLC, Cloud Click, L.L.C., Elevate Consulting International LLC, Cove Solutions LLC, and Lake View Holdings LLC – from selling or helping others to sell any business coaching service or business opportunity and prohibits any further violation of the Telemarketing Sales Rule. The settlement order also imposes a monetary judgment of $10.9 million, most of which will be suspended due to the defendants’ inability to pay.

The Commission vote approving the complaint and stipulated final order was 5-0. The FTC filed the complaint in the U.S. District Court for the District of Utah on January 29, 2019. The Court approved the stipulated final order on Feb. 12, 2019.

NOTE: Stipulated final orders have the force of law when approved and signed by the District Court judge.